Hi Rebecca! At our campus, we put the onus entirely on the fund managers/department business managers who oversee that particular funding. Our central office does not audit for Fly America Act compliance on Expense Reports and should any sort of audit come up the traveler's own department/fund managers are ultimately responsible. Part of Expense Report certification is for department approvers to review funding requirements; they must approve use of funding before the claim gets to our office for final review and approval.

Our expense processor (auditor), reviews flights purchased for Fly America/Open Skies compliance post travel. Pre-travel, our travel coordinators in the central office, our TMC and/or booking tool (Concur - shield icon) are used to vet Fly America compliant flights. The travel director reviews all international travel requests pre-trip to assess the risk level of the destination. During this review, we include the following language on the Concur Request so travelers are notified:

If traveling on Federal Funds, please make sure that flights entering and exiting the US are Fly America Compliant. These flights can be identified with a shield icon in the Concur booking tool. If you need assistance or have questions, please contact the travel team.

In the event of a waiver request, the Office of Grants and Contracts Director and Travel Director would review the circumstances to make a determination. Typically, we would ask the sponsoring agency to review so we had support for any exceptions. We rarely receive requests for exceptions.